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<br />Evidence suggests that the warm species diversity standard of having at least two warm <br />season grasses contributing at least 50 percent of the total relative plant cover is <br />apparently taken from earlier Colorado Mined Land Reclamation Division's Vegetation <br />Guidelines which may no longer be applicable. <br />RECOMMENDATIONS <br />Monitoring of the revegetation status of the 1983 and 1987 reclaimed sites, these areas <br />being at least ten years old and potentially eligible for final bond release at the Southfield <br />Mine site suggests that both sites appear to satisfy the apparent revegetation success <br />standards with respect to total plant cover, forage production and species diversity. <br />However, there are obvious deficiencies with respect to the revegetation success <br />standard of warm season grasses associated with these sites. Unfortunately, it appears <br />that this apparent deficiency might be more a result of changing regulatory polices than <br />anything else. Our recommendation is to revise the warm species diversity standard and <br />then think about whether it is advantageous to commence final bond release monitoring <br />on these older stands. <br />Examination of the species diversity standard reveals that this standard was proposed <br />and approved with no apparent consideration to the site specific conditions found at the <br />Southfield Mine. Previous monitoring efforts documented the unreasonable nature of the <br />old single species diversity standard of not having more than 40 percent relative plant <br />cover. This change was submitted and approved as recommended based on the earlier <br />monitoring data. With this monitoring effort, it would appear that the warm season grass <br />standard of having two species comprising at least 50 percent of the relative cover at this <br />location cannot be justified by the existing data obtained from the Grassland Reference <br />Area. <br />According to the revegetation monitoring schedule in the Southfield Mine permit, each <br />reclaimed site is to be sampled during years 3, 7, 9 and 10 after initial vegetative <br />reestablishment. In order to clarify future revegetation monitoring, Table 10, Revegetation <br />Monitoring Schedule has been prepared showing which reclaimed areas need to be <br />sampled in each year. The 1983 and 1987 reclaimed areas would be sampled as <br />determined necessary by EFCI. <br />Since the vegetation characteristics obtained from the Grassland Reference Area in 1997 <br />where identical to the total plant cover value obtained from the 1987 sampling of this site, <br />there is no reason why this area should again be sampled for purposes of interim <br />reclamation monitoring. <br />9 <br />